Code of Conduct

PHE is committed to conducting business in a legitimate and ethical manner by adhering to the Code of Conduct (COC). To continuously improve corporate governance implementation and align with PT Pertamina's (Persero) COC Guidelines, PHE amended the COC guidelines in 2018, which originally contained PHE Circular Decree of Shareholders dated 22 April 2008 concerning Good Corporate Governance (GCG).

Guidelines, and the Code of Conduct (COC) was amended to become the Code of Conduct and Business Ethics (COC) No. A-003/PHE040/2018-59 dated 20 December 2018. The Company has formulated a Code of Ethics that applies to all employees of the Company as a basic reference for them in acting and behaving in accordance with Best Practices and applicable laws and regulations.

Implementation of The Code of Ethics

1. Give understanding to all employees of the Company that the company is carried out with honesty and in transparent manner, with determination to create a favorable workplace, with a commitment to improving employee welfare.
2. As part of society, it is important for the Company to maintain good relationships in order to build solid fundamental for the company's long-term success and achieve social welfare and economic improvement.
3. As part of the marine transportation community, the determination and commitment to the implementation of the code of ethics is very important to support the Company in dealing with various legal problems and as part of good risk management as well as efforts to strengthen the Company's goodwill and reputation.

The Signing of The Integrity Pact

The Company's Code of Ethics applies to all employees of every level in the organization, including the Board of Directors and the Board of Commissioners. To ensure the effectiveness of its implementation, all organs within the Company are required to sign an Integrity Pact stating their commitment to comply with the points contained in the Company's Code of Ethics simply to build an ethical business culture.

Principles of The Code of Ethics

1. Corporate Ethics related to Employees;
2. Corporate Ethics towards Customers;
3. Corporate Ethics related to The Manufacturer and Provision of Services;
4. Corporate Ethics related to Competitors;
5. Corporate Ethics to Society;
6. Corporate Ethics related to Gratification and Anti-Corruption;

Socialization of The Code of Ethics

The Company socializes the code of ethics through various ways, including directly in various trainings and by utilizing various media, both print and electronic. This consistent and continuous socialization is able to increase employee awareness at various levels of the organization towards the implementation of the company's code of ethics.

Violation of The Code of Ethics and Enforcement of Sanctions

Supervision of compliance with the implementation of the company's code of ethics is the responsibility of the Head of the Work Unit. The Company will apply strict sanctions against any violation of the code of ethics that can be proven. Violation sanctions can be indiscipline actions in accordance with the provisions of the company. The level of sanctions for violations of the Company's Code of Ethics is as follows:

• Minor Sanctions: Written Warning;
• Intermediate Sanctions: Termination of Employment;
• Severe Sanctions: Job Cuts;

As a proof of improved quality of corporate governance implementation, the Company this year did not record any reports of violations of the code of ethics.