PT SAPTA BORNEO UTAMA
Governance Documentation Package
SBU-GOV-004 Strictly Confidential Final / Published

# Internal Control Framework

Framework establishing internal controls, approval authority, segregation of duties, financial controls, audit procedures, fraud prevention and operational governance standards.

## Control Objectives

- Protect company assets.
- Ensure accurate financial reporting.
- Prevent fraud and unauthorized transactions.
- Maintain compliance with financing obligations.
- Support transparent project governance.
- Strengthen operational accountability.

## Control Environment

Control Area | Requirement
--- | ---
Governance Oversight | Board and management supervision
Approval Authority | Defined approval matrix
Segregation of Duties | Separate initiation, approval and execution
Documentation | Complete audit trail
Compliance Monitoring | Periodic review

## Financial Controls

Process | Control
--- | ---
Payments | Dual approval and supporting documentation
Procurement | Vendor verification and purchase approval
Budgeting | Annual budget approval and variance monitoring
Cash Management | Bank reconciliation and treasury reporting
Project Drawdowns | Milestone certification and lender approval

## Fraud Prevention Controls

- Authorized signatory controls.
- Payment verification procedures.
- Vendor due diligence.
- Conflict of interest declaration.
- Whistleblowing channel.
- Independent audit review.

## Audit & Review Framework

Review | Frequency
--- | ---
Bank Reconciliation | Monthly
Budget Variance Review | Monthly
Internal Control Review | Quarterly
External Audit | Annual
Lender Compliance Review | Quarterly

## Control Statement

PT Sapta Borneo Utama is committed to maintaining internal controls that support institutional governance, lender transparency, financial discipline, operational integrity and long-term stakeholder confidence.