Code of Conduct

At the heart of our operations is a strong commitment to ethical behavior, transparency, and accountability. Rooted in our core value of Integrity, our Code of Conduct outlines the principles and standards that guide the actions of every employee, leader, and business partner associated with the company.

The Code is designed not only to comply with laws and regulations but also to cultivate a workplace culture where doing the right thing is the norm. It defines what responsible conduct looks like—whether interacting with colleagues, clients, communities, or regulators—and helps ensure that decisions are made with honesty and fairness.

 

The Code covers key areas of responsibility, including:

  • Respect for People – Promoting a safe, inclusive, and respectful work environment for all.

  • Environmental Stewardship – Encouraging responsible practices that minimize environmental impact.

  • Ethical Business Practices – Addressing conflicts of interest, anti-bribery policies, proper use of company assets, and confidentiality.

Employees are also provided with clear guidelines on the handling of gifts and hospitality, disclosure of personal interests, and the importance of speaking up through established channels to report unethical or questionable conduct.

Additionally, the Code extends to our business partners, setting clear expectations for ethical alignment and responsible collaboration.

By living these values every day, we strengthen trust, uphold our reputation, and contribute to a sustainable future—for our company, our industry, and the communities we serve.

The Code is designed not only to comply with laws and regulations but also to cultivate a workplace culture where doing the right thing is the norm. It defines what responsible conduct looks like—whether interacting with colleagues, clients, communities, or regulators—and helps ensure that decisions are made with honesty and fairness.

Corporate Business Ethics

  1. RELATIONSHIP WITH SHAREHOLDERS
     The Company must ensure the fulfillment of Shareholders’ rights in a transparent, fair, timely, and smooth manner in accordance with the Company’s Articles of Association and other applicable regulations (this is a priority for the Company).

Policies:

  • Provide complete and accurate material information about the Company to Shareholders in accordance with applicable laws and regulations.
  • Establish a mechanism for the General Meeting of Shareholders (GMS) that allows every Shareholder to attend the GMS and cast their vote in accordance with applicable laws and regulations.
  • Ensure that every Shareholder receives their rights in accordance with the provisions of the Company’s Articles of Association, all legally made decisions in the GMS, and applicable laws and regulations.
  • Fulfill obligations and carry out responsibilities in accordance with the Company’s Articles of Association and applicable laws and regulations for the benefit of every Shareholder.
  1. RELATIONSHIP WITH EMPLOYEES
     Employees are a key and strategic asset for the Company.
     The Company provides a safe and conducive working environment, protecting employees from any potential threats to occupational safety and health, and upholds employees’ rights to unionize in accordance with applicable regulations.
     The Company fosters an open, fair, and discrimination-free workplace, regardless of race, ethnicity, tribe, religion, gender, age, or other factors unrelated to employee performance. The workplace is also free from any form of harassment, threats, or acts of violence.

Policies:

  • Treat employees as strategic partners in achieving the Company’s goals.
  • Respect and fulfill employee rights in accordance with prevailing Company Regulations.
  • Provide freedom to express constructive thoughts and opinions.
  • Encourage and support employees in developing relevant knowledge and skills.
  1. RELATIONSHIP WITH CUSTOMERS
     The Company prioritizes customer satisfaction and trust by consistently striving to provide high-quality service and innovative solutions.

Policies:

  • Ensure that customer service is carried out professionally, objectively, honestly, and based on the best available knowledge.
  • Ensure that the Company’s business activities comply with contractual obligations and are supported by sound quality and environmental management systems.
  • Ensure that all business agreements with customers are conducted fairly, based on equality, fairness, and professionalism.
  • Provide and manage communication channels to make it easy for customers to submit complaints, suggestions, and feedback.
  • Respond to and follow up on every customer complaint, suggestion, and feedback.
  • Foster good relationships with customers based on the principles of equality, fairness, and mutual benefit.
  1. RELATIONSHIP WITH THE GOVERNMENT
     The Company is committed to developing and maintaining good relationships and effective communication with the Government by adhering to business regulations and complying with applicable laws and regulations. All interactions with government officials must be conducted at arm’s length and avoid any form of collusion or misconduct.
     The Company consistently engages in business activities that have a positive impact and add value to economic growth, both directly and indirectly.

Policies:

  • Comply with all laws and regulations issued by the government.
  • Fulfill all obligations to the Government in accordance with applicable laws and regulations.
  • Support government programs as part of the Company’s social responsibility.
  1. RELATIONSHIP WITH CREDITORS
     The Company maintains relationships with creditors based on commitment, trust, honesty, mutual respect, and equal opportunity. The Company exercises prudence in the use of creditor funds.

Policies:

  • Provide current, accurate, and reliable information to creditors and prospective creditors.
  • Select creditors based on credible and accountable qualifications.
  • Conduct risk and benefit analysis before entering into credit agreements.
  • Accept loans bound by legally valid agreements that emphasize the principles of fairness and equality.
  • Fulfill creditors’ rights and strive to repay loans in accordance with the agreed written credit agreements.
  • Disclose information transparently regarding the use of funds to strengthen creditor confidence.
  1. RELATIONSHIP WITH BUSINESS PARTNERS
     The Company establishes its goods and services procurement policy based on the evaluation of quality, price, service, and other benefits provided by Business Partners (Suppliers and Contractors). The Company maintains honest, open, and effective communication while safeguarding the confidentiality of data and information in accordance with applicable regulations, including addressing complaints and objections from Business Partners.

Policies:

  • Carry out the procurement of goods and services in a fair and transparent manner.
  • Provide equal opportunities to all Suppliers and Contractors.
  • Fulfill the rights of Suppliers and Contractors as stipulated in the agreed contracts.
  • Maintain relationships and cooperation with Suppliers and Contractors based on professionalism, equality and fairness, trust, mutual respect, and free from coercion or collusion.

Maintain good relationships with Suppliers and Contractors who have a strong track record, and impose sanctions on those who commit violations.

 

  1. RELATIONSHIP WITH COMPETITORS
     The Company views and positions competitors as drivers for continuous improvement of competencies to remain competitive in the market. The Company upholds business ethics and competes fairly and ethically with competitors.

Policies:

  • Promote mutual respect among competitors.
  • Pursue innovation in line with the growing and increasingly open competition.
  • Focus on business excellence and high-quality services.
  • Use competitors or other companies as benchmarks to improve the Company’s performance.
  • Avoid or refrain from collaborating with competitors or any parties in ways that violate the principles of fair competition.

     

  1. RELATIONSHIP WITH THE COMMUNITY
     The Company consistently shows concern for the condition of communities where it operates and believes that fostering positive and harmonious relationships—free from discrimination—and supporting community development are essential foundations for the Company’s long-term success. The Company’s social programs are aimed at improving quality of life and empowering the potential of surrounding communities.

Policies:

  • Respect local cultural values and consider environmental aspects in the areas where the Company operates.
  • Implement community empowerment initiatives and be an engaged corporate citizen by contributing to humanitarian, health, education, and cultural activities, while encouraging active participation of Company personnel in social activities.
  • Optimize the delivery of the Company’s social programs to the community.
  • Prohibit employees from making promises to the community beyond their authority.

  1. RELATIONSHIP WITH THE MASS MEDIA
     The Company views the mass media as a partner in disseminating information and promoting its business activities, as well as in building a positive corporate image. The Company consistently maintains good and proactive relationships with the media to communicate its policies, business activities, and achievements.

Policies:

  • Accept input from the mass media delivered through proper journalistic processes as constructive feedback to help improve the Company.
  • Provide relevant and balanced information to the media about the Company’s business activities and industry.
  • Treat journalists fairly in order to foster a positive corporate image.
  • Receive and respond to constructive suggestions and criticisms published by the media, with due consideration for the Company’s best interests.

  1. RELATIONSHIP WITH PROFESSIONAL ORGANIZATIONS
     The Company establishes good and sustainable cooperation with professional organizations to gain insights into industry developments, identify business opportunities, and resolve emerging issues by:
  • Adhering to and implementing the standards and regulations set by professional organizations.
  • Providing fair and equal treatment to the professional organizations the Company is affiliated with.
  • Fulfilling the rights and obligations as stipulated by the professional organizations.

Ethics of Corporate Conduct

  1. INTEGRITY AND COMMITMENT OF COMPANY PERSONNEL
     All Company personnel, both individually and collectively, must uphold honesty, manners, discipline in work, social ethics, and business ethics in carrying out daily business activities with both internal and external parties of the Company.

To this end, Company personnel are required to:

  • Prioritize the interests of the Company over personal, group, or other parties’ interests.
  • Strive to achieve work results (performance) in accordance with the Company’s standards of success, excel to build a long-term career, and produce work beneficial to the Company.
  • Implement principles of awareness, thinking, attitude, and ethical behavior to ensure the successful implementation of Good Corporate Governance (GCG).
  • Uphold the highest standards of integrity and avoid conflicts of interest and misuse of position.
  • Avoid fraudulent actions or illegal activities in any operational activities that could harm the Company.
  • Avoid practices of corruption, collusion, and nepotism (KKN) in all Company operations.

Maintain the Company’s good name by behaving in accordance with Company values, consistently adhering to Company work guidelines and applicable laws and regulations, and always upholding the Company’s Code of Ethics.

2. COMPLIANCE WITH LAWS AND REGULATIONS
 Every Company personnel is obliged to comply with all applicable laws and regulations. Any form of non-compliance by Company personnel with the applicable laws and regulations will not be tolerated. Issues requiring firm action related to legal matters should be consulted with the Corporate Legal Unit.

  1. WORK RELATIONSHIPS

A. Relationships and Cooperation Among Company Personnel

The Company prohibits any actions that do not support or that hinder the creation of good cooperation among Company personnel in carrying out their duties and responsibilities to achieve group or Company goals.

Good relationships among Company personnel create a conducive work environment. Therefore, every Company personnel is required to:

  • Build teamwork and work professionally to achieve optimal performance.
  • Trust and give the benefit of the doubt to fellow Company personnel.
  • Respect each other, openly accept criticism and suggestions, and resolve issues through consensus.
  • Remind each other to do good, openly accept and provide constructive input.
  • Perform work in accordance with duties and responsibilities, and comply consistently with established rules, policies, and operational procedures. 
  • Foster exemplary behavior, honesty, discipline, and professionalism at work. 
  • Inform leadership if there are indications of violations.
  • Respect the work and creativity produced by employees.

B. Work Environment

Company personnel must create a work environment free from discrimination, harassment, immoral acts, threats, and violence. The Company is committed to developing a diverse workforce and providing a workplace where every employee is treated fairly and respectfully, with equal opportunities for work and promotion.
 All employees and job applicants are treated and evaluated based on skills, qualifications, abilities, and competencies. Decisions are not based on differences in race, ethnicity, tribe, religion, gender, age, personal relationships, place of origin, disability, ideology, marital status, or other special conditions protected by law.
 Discrimination against an employee or job applicant is a serious violation of equal employment opportunity and Company policy.

Every Company personnel is prohibited from any form of harassment and immoral acts toward anyone, including:

  • Verbal harassment such as offensive words, dirty jokes, or insults.
  • Physical harassment such as inappropriate touching or acts intended to demean.
  • Harassment through images such as posters, cartoons, graffiti, writings, or obscene gestures.
  • Sexual harassment and other related behaviors.

The Company upholds moral values and norms. Immoral acts not only damage the Company’s image and reputation but also create an uncomfortable work atmosphere. Every Company personnel is obliged to create and maintain a comfortable work environment free from immoral acts.

  1. CONFLICT OF INTEREST AND ABUSE OF POSITION

     A conflict of interest is a situation where an individual, due to their position or authority within the Company, has personal interests that may affect the objective performance of their duties. Every Company personnel must avoid any potential conflicts of interest that could harm the Company. Company personnel are prohibited from engaging in activities that directly or indirectly benefit their own interests, family, or relatives within the Company.

To avoid conflicts of interest, personnel who find themselves in such situations must either withdraw from them or inform the responsible party.

Personnel must adhere to key principles to prevent conflicts of interest and abuse of position:

  • Avoid conflicts of interest in any form and always prioritize the Company’s interests over personal or other parties’ interests.
  • Do not conduct transactions or use the Company’s name, assets, or facilities for personal, family, relative, or group benefit.
  • Do not accept or give gifts or benefits in any form related to their position in the Company.
  • Do not misuse confidential information or Company business data for external interests.
  • Do not hold positions in other companies/institutions that have or seek business relations or competition with the Company.
  • Do not abuse their position to grant special treatment to family, relatives, groups, or other parties at the Company’s expense.
  • Do not give preferential treatment to Customers, Business Partners, or others beyond Company policy.
  • Report and request permission/approval for any outside interests or activities during working hours through the chain of command.
  • Inform Company leadership if having family ties with Business Partners or others and agree to be excluded from decision-making involving such parties.

Personnel who will hold social organization positions related to the Company must obtain prior approval from their immediate supervisor.

  1. DATA AND INFORMATION CONFIDENTIALITY AND DISCLOSURE POLICY
     The Company establishes policies regarding the disclosure of Company information to ensure the security and confidentiality of information and to ensure that material information required to be disclosed is shared fairly and equitably with the public and relevant parties without favoritism.

Personnel must act cautiously to prevent intentional or accidental leakage of confidential information. Employees must verify that all working papers and documents created, copied, faxed, stored, or discarded consider the risk of unauthorized access. To this end, personnel must comply with the following:

  • Take responsibility for appropriate actions to ensure that information sources are protected proportionally to their value and risk.
  • Disclosure of important Company information to stakeholders is only permitted by authorized officers or with written approval from the Board of Directors who authorize designated Company officials (one gate policy).
  • Personnel must not disclose confidential information to unauthorized stakeholders during or after employment.
  • Disclosure of important information to stakeholders is only allowed after obtaining permission from authorized Company officials or a court order.
  • Personnel are prohibited from discussing confidential Company information with family members (spouse, children, or other relatives) or unauthorized third parties.
  • The Company regulates access procedures to data and information, whether computerized or not.
  • Personnel are prohibited from using internal information for personal, family, or third-party securities trading unless the information is publicly known.
  • Personnel leaving the Company must return all data owned to the Company.

 

  1. USE OF ELECTRONIC COMMUNICATION

    The Company’s electronic communication system is a Company asset consisting of devices and procedures for the use of electronic information. Electronic information includes electronic data such as: text, audio, images, designs, photos, electronic mail (e-mail), or similar formats.

All use of electronic communication must comply with Company policies and refer to the Company Policy on information and communication system security. The use of electronic communication tools and electronic information will be monitored by Company management.

Company personnel are responsible for the handling and use of electronic information communicated through the Company’s electronic communication system. All hardware, software, and data must be properly safeguarded to prevent misuse, damage, loss, alteration, or unauthorized access.

  1. PERSONAL DATA AND CONFIDENTIALITY
  • Protect and use personal data and confidential information only for authorized purposes.
  • Maintain confidentiality and do not disclose to unauthorized parties.
  • Handle data according to applicable laws and Company policies to prevent misuse.

     

  1. INSIDER TRADING
  • Employees with insider information must not use or share it for personal gain.
  • Trading Company shares or financial instruments based on insider information is prohibited.
  • Violations may lead to legal and disciplinary actions.

     

  1. CONFLICT OF INTEREST
  • Avoid activities or relationships that conflict with Company interests.
  • Disclose any potential conflicts to management promptly.
  • Act in the Company’s best interest, avoiding use of position for personal benefit.

     

  1. POLITICAL ACTIVITIES
  • Employees have the right to participate in political and social activities as citizens.
  • The Company does not force, influence, or direct political participation.
  • Employees must:
    • Perform duties professionally and neutrally.
    • Not serve as political party officials.
    • Not use Company position, assets, or facilities for political purposes.
    • Not wear political or social organization symbols at work.
    • Resign if they want to become party officials or legislative members.

       

  1. OUTSIDE COMPANY ACTIVITIES
  • Outside activities that support work tasks are permitted, such as memberships in associations.
  • Employees may participate in professional, social, sports, or religious organizations unrelated to work.
  • Conditions include:
    • Organizations must be government-recognized and align with Company values.
    • Do not misuse Company position, assets, or facilities for outside activities.
    • Outside activities must not interfere with work hours, concentration, or priorities.
    • Activities should positively represent the Company where possible.

       

  1. PROTECTION AND USE OF COMPANY ASSETS
  • Company assets are for business purposes only, not for personal use, sale, loan, or disposal without permission.
  • Taking Company assets offsite without permission is theft.
  • The Company protects assets from loss, theft, and misuse.
  • Assets include tangible property and intellectual property such as patents and copyrights.
  • The Company manages and protects intellectual property value and usage.
  • Employees must:
    • Use assets according to their position and job scope.
    • Use assets as intended and maintain their condition.
    • Protect assets from damage and loss.
    • Use assets efficiently to achieve Company goals.
    • Return assets after their assignment ends.

       

  1. OCCUPATIONAL SAFETY, HEALTH, AND ENVIRONMENT (OSHE)
  • The Company prioritizes occupational health and safety as well as environmental preservation for long-term success.
  • The Company ensures a safe and healthy workplace by complying with applicable OSHE laws and regulations.
  • Every employee is responsible for taking appropriate steps to prevent workplace accidents and maintain a safe and healthy environment.
  • Key shared responsibilities include:
    • Complying with all OSHE-related regulations, both general and Company-specific.
    • Actively participating in OSHE programs at work.
    • Prioritizing preventive actions to avoid accidents.
    • Being alert and responsive to emergencies such as security threats, fires, and accidents.
    • Reporting all incidents and accidents promptly to supervisors and relevant authorities according to regulations.
    • Conducting regular inspections and evaluations of facilities, equipment, and detection systems within their authority.
    • Collaborating with stakeholders to raise awareness of OSHE importance and continuously improve workplace conditions.

       

  1. RECORDING DATA, REPORTING, AND DOCUMENTATION
  • Accuracy and reliability in handling Company data are crucial to ensure precise reports used in decision-making processes.
  • Accurate recording and reporting reflect the Company’s reputation and credibility.
  • Accurate and complete documentation of business and financial data is the responsibility of every Company employee.
  • Any deliberate attempt to obscure, improperly archive, or falsify documents or transactions is a violation. Even the smallest mistake can have serious consequences and may be illegal.
  • Therefore, all employees must manage Company data carefully, neatly, and responsibly by:
    • Recording and preparing reports based on true and reliable sources and verifying their accuracy.
    • Not altering, adding, reducing, damaging, deleting, moving, or hiding documents, data, information, or reports that should be submitted and may affect the Company’s business activities.
    • Conducting bookkeeping and/or documentation properly without deviations or fraud that violate Company policies or applicable laws and regulations.
    • Presenting reports based on principles of transparency and accountability. Reports must be accurate, relevant, timely, free from interpretation, and clearly show relevant facts.
    • Documenting reports according to the Company’s internal policies.

       

  1. ABUSE OF NARCOTICS, ILLEGAL DRUGS, ALCOHOL, AND GAMBLING
  • Healthy behavior based on moral and ethical values of every employee is believed to influence their contribution to the Company’s performance and the Company’s image. Therefore, every employee:
    • Is strictly prohibited from abusing narcotics and illegal drugs.
    • Is prohibited from consuming alcohol or alcoholic beverages while at the workplace and must maintain a healthy and clean work environment.
    • Is prohibited from engaging in any form of gambling.
    • Abuse or possession of dangerous substances, alcoholic beverages, and gambling in the Company office or while representing the Company will be subject to strict disciplinary actions according to Company Regulations.

       

  1. COMPANY IMAGE
  • All employees must maintain the Company’s good name through speech, attitude, and behavior aligned with the Company’s Values and always comply with the Company’s work guidelines and applicable laws and regulations, while upholding the Company’s Code of Ethics.

Whistleblowing System

Reporting Concerns and Violations

To foster a positive and collaborative working relationship between the Company and its employees, we promote transparent communication channels for addressing any issues or challenges employees may face. This is facilitated through the Whistleblowing System (WBS) Team. In the event of a dispute, the Company is committed to resolving the matter amicably through dialogue and mutual agreement, while ensuring compliance with Company Regulations and applicable laws.

If you wish to report a concern, please contact us at:

integrity@logindo.co.id
 or
 lapor@logindo.co.id

We appreciate your commitment to maintaining a culture of transparency, accountability, and trust.

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