WHISTLEBLOWING SYSTEM

Background

PT Sarana Menara Nusantara Tbk and or Its Subsidiaries (collectively referred to as the "Group") are deeply committed to implement Good Corporate Governance (“GCG”) principles, ethical business practices, and compliance with applicable laws and regulations. As part of these efforts, the Group has established a Whistle Blowing System (“WBS”) to facilitate a confidential, secure, and responsible reporting of suspected misconduct within the Group. This WBS strengthens accountability and aligns with our dedication to transparency and clean business practices.  

Definition

The WBS is an independent, confidential reporting mechanism that allows employees, management, vendors, and other stakeholders to report any suspected misconduct securely. Types of reportable misconduct include, but are not limited to:

1. Fraud;
2. Violations of laws regulations, or internal Group policies;
3. Corruption, collusion, or conflict of interest;
4. Discriminatory actions, sexual harassment, and other workplace misconduct;
5. Substance misuse, such as drugs or narcotics; and
6. Any other acts that violate ethical business conduct or Group’s corporate governance.

Objective

The WBS is designed as a channel for reporting any misconduct or suspected misconduct as mentioned above, allowing stakeholders to voice concerns without fear of retaliation. This aligns with the Group’s commitment to integrity, accountability, and transparency across all levels of operation.  

Protection for The Whistle-Blower

The Group is committed to maintain the confidentiality of whistle-blowers’ identities and offers robust protections against any form of retaliation. Any information provided through the WBS will be treated with strict confidentiality and will only be accessed by WBS Committee. The Group takes all necessary measures to protect whistle-blowers who act in good faith, ensuring a safe environment for reporting misconduct.  

Whistleblowing Management Process

Group has specified the process for whistleblowing reporting through WBS Channel. Every report or an issue is submitted through the WBS channel (e.g: email, phone number, or other) and it undergoes directly to WBS Committee. Roles and Responsibilities of WBS Committee described separately in WBS Charter.

Based on preliminary analysis by WBS Committee, the report or issue will be forwarded or assigned to resolve the problem according to type or urgency or content of the report. All investigative procedures adhere to strict confidentiality protocols, ensuring that only WBS Committee that have access to sensitive information and get updated by the current status of the issues. Below is the mechanism by which a report is processed by the Group within the WBS:

Reports can be submitted via the following WBS channels:

Email: whistleblower.protelindogroup@protelindo.co.id

SMS / WhatsApp: 0817-492-2964 / 0878-4453-0366

Report Anonymously: https://www.ptsmn.co.id/contact- us/whistleblowing-system/form  

To facilitate a comprehensive investigation, the following details should be provided when submitting a report:

• Description of the incident (including details of suspected misconduct);
• Names of involved parties;
• Date and time of occurrence;
• Description of how the incident occurred; and
• Any supporting evidence or relevant documentation, if available.

Providing clear and accurate information helps ensure a swift and thorough investigation process.