Anti-Corruption Policy

To facilitate the implementation of the Anti-Corruption policy, PHE Subholding Upstream successfully conducted the first surveillance audit on the Anti-Bribery Management System (SMAP) ISO 37001:2016 Anti-Bribery Management System (SMAP) in 2021. Additionally, PHE Subholding Upstream ensures that

SMAP implementation in Subsidiaries runs smoothly in all operational activities aimed at preventing bribery. As of the end of 2021, there are 6 (six) subsidiaries that have been certified to ISO 37001:2016 SMAP, namely:

1. PT Pertamina EP
2. PT Pertamina Hulu Indonesia
3. PT Pertamina EP Cepu
4. PT Pertamina Internasional EP
5. PT Pertamina Drilling Services Indonesia
6. PT Elnusa Tbk

SMAP Guidelines No.A12-001_PHE01000_2022-S9

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Provisions on Gratification

PHE Subholding Upstream issued Gratification Control Guidelines No. A13-002/PHE01000/2021-S9 dated 31 December 2021 to update the Guidelines for Gratification, Rejection, Acceptance, and Giving Gifts/Entertainment Souvenirs in 2014, that can be downloaded on below link:

Gratuity Control Guidelines No A13-002 PHE01000 2021 S9

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Integrity Pact

PHE Subholding Upstream's Board of Commissioners and Board of Directors are committed to conducting business professionally, which includes avoiding conflicts of interest, maintaining trust, and adhering to Good Corporate Governance principles, in accordance with PT Pertamina’s (Persero) moral character and code of conduct as guidelines for daily operational activities.

Guidelines for Conflict of Interest No.A-004/PHE040/2018-S9

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LHKPN Reporting

PHE Subholding Upstream has a policy of submitting the State Administrators Wealth Report (LHKPN), which is required for all PHE Subholding Upstream employees, as stated in the Decree of the Board of Directors of PT PHE Subholding Upstream No. Kpts-019/PHE0000/2020-S0 dated 30 November 2020 concerning the Obligation to Submit the State Administrator Wealth Report to All Employees in the PHE Subholding Upstream Environment. In accordance with the Decree of the Board of Directors, employees with the position of Assistant Manager/Equivalent or higher are required to report LHKPN via the website elhkpn.kpk.go.id, while employees with the position of Staff are required to report LHKPN via the LHKPN PHE Subholding Upstream application. This was followed by the issuance of a decree for the implementation of each of the Subsidiary's Directors.

LHKPN Guidelines No.A13-001/PHE01000/2022-S9

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