A. Violation Reporting System

The mechanism for Submission of Violation Reports
The Company provides a channel for complaints of violations through the decision of the board of directors Number: 34/SK/WK/2017 dated December 11th, 2017, regarding the Guidelines for the Violation Reporting System (SPP)/Whistleblowing System (WBS) of PT Waskita Karya (Persero) Tbk.
This channel aims to detect fraud that occurs early. Through this team, the Company prevents the occurrence of fraud with a comprehensive supervision pattern and involves all employees to provide a sense of security for all parties interacting with the Company.

The Mechanism for Handling Violation Reports
If there are some indications of code of conduct violations or other disciplinary violations can be submitted to the Company Secretariat. The Company will follow up on reports that have the potential to be materially detrimental and may damage the Company's image. Those caused by deviation, manipulation, and others. Reports or complaints regarding those violations will be handled with the following mechanisms:
• The reporting party who knows of fraud, irregularities, or violations by the Company's internal, are required to make a report or submit it to the Company Secretariat. these things must be conveyed in detail or detail accompanied by relevant data or evidence.
• The company secretariat receives and examines reports of violations, whether they meet the requirements for further processing.
• Shareholders of Series A Dwiwarna, the Board of Commissioners, or the Board of Directors who receive the report file conduct an examination or investigation through their respective organs to prove the report of veracity.
• The investigation by the SPP management organ is the Internal Audit Unit and the Audit Committee.
• Shareholders, the Board of Commissioners, or the Board of Directors impose sanctions on the reported party and provide rewards to the complainant.
• Series A Dwiwarna Shareholder, the Board of Commissioners, or the Board of Directors submit a report to the Corporate Secretariat on the follow-up to reports of violations.

Protection for Whistleblowers
Reports of violations that happened, they must be made with good intentions and not as a personal complaint or based on slander and bad intentions. Whistleblowers are required to clearly state their identity on the reports they make along with relevant supporting evidence. The Report's Recipient must keep the Reporter's identity confidential as part of the efforts of The Company to protect the whistleblower. The Company is required to follow up on every report received following applicable procedures and mechanisms. The Company will also provide legal protection by the applicable laws and regulations of the provisions.

Rewards/Sanctions Report
For every Report whose handling is proven to be able to return the Company's money/assets, get an award or reward from Management. Meanwhile, if the Report submitted is proven to be slander, the Management will apply the most severe sanctions to the complainant.

Management of Violation Reporting System
Reports of violations are shown through a standard mechanism and are managed professionally by the Corporate Secretariat to detect fraud occurring as early as possible.

Violation Reporting Media
The Reports of violations can be submitted by:
Corporate Secretariat
Jl. MT Haryono Kav. No. 10 Cawang East Jakarta
Tel. 021-8508510
Fax. 021-8508506

Number of Complaints and Follow-up in 2018
During 2018, there were no complaints regarding reports of violations within the Company.

Monitoring and Evaluation
Monitoring and Evaluating are carried out on the effectiveness of the violation complaint channels that are already available to be updated in the future. Through such monitoring and evaluation, the Company can accommodate and respond to complaints of violations from stakeholders quickly, on a timely and accurate basis. These aims to minimize and prevent the potential for reputational risk and increase public trust in the Company.

B. Gratification Policy

Definition and Background
As a gratification control guide for Waskita personnel, the Company issued a gratification control guideline with the latest edition on 31st August 2017.
The Company defines Gratification as an activity of giving and/or receiving gifts/souvenirs and entertainment, Whether it received domestically or abroad, which is carried out by the Company's personnel to their authority/position in the Company so that it can cause a conflict of interest that affects independence, objectivity, and professionalism of the Company's personnel.
The Company realizes that in carrying out business activities. it is unavoidable to avoid relationships and interactions between parties, both internally and externally, to establish harmonious and sustainable cooperation and relationships. In this cooperation, the possibility of giving gratuities from one party to another is also unavoidable. Therefore, to maintain business relationships with stakeholders, the Company regulates matters related to gratification and the procedures or reporting mechanisms.
The Company has also published a gratuity management manual which is intended to create transparent and accountable business management of the Company.

Sanctions for Violations
Violation of the provisions written in the gratification management manual will be subject to sanctions following the provisions and regulations applicable in the Company.
Gratification has a broad definition as an activity of giving money, goods, rebates (discounts), commissions, interest-free loans, travel tickets, lodging facilities, tourist trips, free medical treatment, and other facilities. In addition, gratuities can also be in the form of gifts from employees to other parties or acceptance by employees of the Company from other parties.
The Company has a strict policy on gratification activities. The rules regarding gratification are contained in Law no. 20 of 2001 concerning Amendments to Law no. 31 of 1999 concerning the Eradication of Criminal Acts of Corruption and Waskita Circular No. 06/SE/WK/2017 dated March 30, 2017, concerning Guidelines and Limitations of Gratification. Every receipt of gratuity that is considered a bribe must be reported to the Corruption Eradication Commission (KPK).
During 2017, there were no gratuities given to the Company's Officers and Employees.