PT SAPTA BORNEO UTAMA
Governance Documentation Package
SBU-GOV-005 Strictly Confidential Final / Published

# Compliance & Ethics Policy

Policy establishing ethical conduct, compliance obligations, anti-corruption standards, conflict of interest requirements, whistleblowing procedures and corporate integrity principles.

## Policy Objectives

- Promote ethical business conduct.
- Ensure compliance with applicable laws and regulations.
- Protect stakeholder interests.
- Prevent corruption and misconduct.
- Support institutional governance standards.
- Maintain corporate reputation and integrity.

## Core Ethical Principles

Principle | Description
--- | ---
Integrity | Act honestly and responsibly.
Transparency | Provide accurate information.
Accountability | Accept responsibility for decisions.
Fairness | Treat stakeholders equitably.
Compliance | Follow legal and regulatory obligations.

## Anti-Corruption Standards

- Zero tolerance for bribery and corruption.
- Prohibition of improper payments.
- Mandatory record keeping.
- Due diligence on third parties.
- Reporting of suspected violations.

## Conflict of Interest Policy

- Disclosure of potential conflicts.
- Avoidance of self-dealing transactions.
- Independent review where required.
- Annual conflict declarations.
- Board oversight of material conflicts.

## Whistleblowing Framework

Item | Requirement
--- | ---
Reporting Channel | Confidential
Anonymous Reporting | Permitted
Retaliation Protection | Required
Investigation Process | Independent Review
Board Notification | Material Cases

## Compliance Oversight

Function | Responsibility
--- | ---
Board of Commissioners | Compliance oversight
Board of Directors | Policy implementation
Management | Day-to-day compliance
External Auditors | Independent review

## Policy Statement

PT Sapta Borneo Utama is committed to conducting business with integrity, professionalism and accountability while maintaining compliance with applicable laws, financing agreements, governance standards and ethical principles.