Code of Conduct


The Company’s commitment to upholding the good corporate governance principles of transparency, accountability, responsibility, independence and fairness throughout our operations is described in the Company’s Code of Conduct, which defines the accepted standards of behaviour in interactions with colleagues, employees, shareholders, suppliers, and regulatory officials.

The Code of Conduct provides guidance for employees on:

  1. Improving accountability, transparency, and compliance with applicable laws and regulations;
  2. Implementing tasks with the highest degree of professionalism and integrity;
  3. Avoiding giving or accepting inappropriate corporate gifts, bribery and kickbacks in any form and for any reason;
  4. Avoiding activities which may give rise to a conflict of interest with their work; and
  5. Protecting the Company’s proprietary information, both during and after an employee’s term of employment with the Company.

Comprehensive Application of the Code of Ethics in the Company

The Code of Conduct applies equally to all employees and members of the Company, up to and including the BOC, BOD and Board of Management.

Management has socialized the Company’s Code of Conduct to all employees from headquarters to stores and distribution centers with the Company’s Code of Conduct to create a motivated and directed work force and to provide clarity of acceptable practices. This continuing engagement creates a positive working environment, which is readily available and visibly noted in each of our stores.

In combination with well communicated compliance and internal control measures, the Code of Conduct underpins the Company’s effective corporate culture, giving rise to the focused cooperation that allows the Company to grow effectively and rapidly.


Code of Conduct Implementation and Compliance

The Code of Conduct, initially released in 2002, is continually updated. A booklet is presented to each employee and stresses the need to be part of the Company team. The Code of Conduct provides a conceptual angle by stressing a moral foundation in achieving goals and a practical angle by outlining specific definitions and prohibitions, such as conflict of interest, giving and receiving gifts and gratuities, regulatory compliance, information confidentiality and reporting of unethical behavior.

On April 25, 2019, the Board of Management signed a renewed the pledge of integrity from the previous one in 2014.

The pledge declares to commit and consistently apply Good Corporate Governance principles as well as compliance to the Company’s Code of Conduct, including upholding the Vendor’s Code of Conduct, at all times.

On April 1, 2021, the Company updated and reinforced the Code of Conduct which is in the form of Company Regulation 2021-2023 to all employees through the distribution of the new, updated booklet. Each employee was required to sign and comply toward the Code of Conduct.

In compliance to OJK Regulation No. 33/POJK.04/2014 dated November 23, 2021 both BOC and BOD have formed the “Board of Commissioners Guidelines and Work of Conduct, or Board of Commissioners Charter” on March 17, 2022 and “Board of Directors Guidelines and Work of Conduct, or Directors Charter” respectively, which have been approved and signed by all members on November 23, 2021. The copy of the BOC and BOD Charters have been published in details and are available at the Company’s website.

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Board of Commissioners Guidelines and Work of Conduct  983 KB
Board of Directors Guidelines and Work of Conduct  1044 KB

Anti-Corruption and Gratuity Control Policies

The Company’s Code of Conduct sets out the Company’s policies and procedures for addressing gratuities, bribery, and kickbacks in any form from external parties. Anti-fraud and anti-corruption messages are also promoted to all management, employees and suppliers through the dissemination of the Code of Conduct and the Company’s whistleblower policy.