Good Corporate Governance

Code of Conduct

EXISTENCE OF ETHICAL CODE

Code of Ethics or Conducts is applied by all GTSI members as the basis to build and manage behavior consistently according to the applicable regulation within and without the Company’s environment.

COMMITMENT IMPLEMENTATION OF ETHICS CODE

Implementation of this code of ethics is an attempt to:

a. Provide understanding to all Company persons that the Company operates in an honest and open manner, resulting in a good working environment, with low employee turnover and improved welfare.

b. Being part of a particular community, because maintaining good relations is fundamental to the Company's long-term success in achieving social welfare and improving the economy.

c. Being part of the marine transportation services business community, because the implementation and commitment to this code of ethics can support the Company in various court cases, as well as being a part of good risk management, and able to build goodwill and reputation of the Company.

The Code of Ethics applies to all of the Company's employees at every level of the Company's organization. Employees, Directors and Board of Commissioners are required to sign a statement of compliance commitment to the Company Code of Conduct.

CONTENTS AND CODES OF ETHICS

- Company Ethics of Employees
- Company Ethics to Customers
- Company Ethics on Manufacturers and Service Providers
- Company Ethics on Competitors
- Company Ethics to the Community
- Corporate Ethics against Anti-Corruption Gratuities


SOCIALIZATION OF BUSINESS ETHICS GUIDELINES

Socialization is done by various methods such as face to face and through various media, both print and electronic. Throughout socialization of corporate ethics codes involving all employees at all levels of the organization has been conducted.

SIGNING OF INTEGRITY PACT

The Company requires every employee and Company management to sign an Integrity Pact on compliance with the Code to ensure that all Company organs are committed to building sound business ethics and culture.

ENFORCEMENT OF BUSINESS ETHICS AND EMPLOYEE ETHICS

Guidelines apply without exception to everyone within the Company. Enforcement of violations of the code of conduct is in the form of serious reprisals which may result in disciplinary action in accordance with applicable Company regulations. Implementation of the Company's code of ethics compliance control becomes the responsibility of each Head of Work Unit.

SANCTIONS FOR EACH TYPE OF VIOLATION

To prevent indisciplinary act and to give deterrent effect to the violator of code of ethics, the Company will impose sanctions that can be categorized into three types of sanctions:

1. Minor sanction: Written warning
2. Moderate sanction: Employment termination
3. Severe sanction: Employment termination

Up until now, sanctions imposition is still focused on the crew. Whereas, for employees in the office, the sanction refers to the Company’s Regulations.
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