The appointment of Corporate Secretary is regulated in FSA Regulation No. 35/POJK.04/2014 concerning Corporate Secretary of Issuers or Public Companies and IDX Regulation No. 1-E concerning Obligations to Submit Information. Corporate Secretary is responsible to the Directors, and is appointed/dismissed based on the Directors’ Decree with the approval of the Board of Commissioners. Corporate Secretaryhas strategic function, as a liaison among the Company and shareholders, FSA, IDX, and other stakeholders. In addition, Corporate Secretary also has the important role in facilitating communication among the Company’s organs, relationship between the Company and stakeholders, and compliance with laws and regulations.

Corporate Secretary is responsible to the Directors, and is appointed/dismissed based on the Directors Decree with the approval of the Board of Commissioners. Based on the Directors’ Decree No. 007/MF/III/ 2016 dated 16 March 2016, Corporate Secretary is chaired by Andre Andreas Hendjan. In his brief profile, Andre is Indonesian citizen, Bachelor of Economics from Trisakti University, Jakarta, 2000. previously, he was Tax Manager of the Company’s Group.

Good Corporate Governance (GCG) in the Company is the implementation of traditional values that have been built and adopted from generation to generation. Malindo’s cultural values, which consist of good teamwork, upholding integrity, prioritizing customer satisfaction, and commitment to working over standards, serve as the guideline in every business process and the evaluation basis for the Company’s achievements.

In implementing GCG principles, the Company refers to 5 (five) basic principles, namely: transparency, accountability, responsibility, independence, and fairness, as released in the General Guidelines for Good Corporate Governance issued by the National Committee on Governance Policy (KNKG). In addition, GCG implementation in Malindo environment is complied with various provisions, such as Law of the Republic of Indonesia, Regulation of Financial Services Authority (OJK) and Regulation of Capital Market and Financial Institutions Supervisory Agency (Bapepam-LK), as well as the Company’s Articles of Association.

The Company also has a set of GCG devices of Operational Policies and Procedures, including

1.Corporate Governance Guidelines

2.Board Manual

3.Code of Conducts

4.Audit Committee Charter

5.Internal Audit Charter

6.Whistleblowing System Guidelines

Audit Committee of the Company has Audit Committee Charter as a guideline in carrying out its roles, duties, and responsibilities to assist the Board of Commissioners. The Audit Committee Charter covers the duties and responsibilities of Audit Committee; the rights and authorities of Audit Committee; composition, structure and membership requirements; relationship with related parties; Audit Committee meetings; Audit Committee reports; as well as conflict and code of ethics of Audit Committee. Audit Committee Charter No. 067/CS/XI/13 was ratified on 11 November 2013 and reviewed periodically to conform to the prevailing regulations.

Until now, Malindo has not established a specific committee to monitor the implementation of the Company’s risk management. However, the Board of Directors periodically conducts a review of the implementation of the Company’s risk management by taking into account the related costs and risks. In addition, the Company also continuously evaluates the implementation of risk management and provides proposed improvements in achieving continuous improvement in every existing line process.

Evaluation is conducted by each risk owner and the Risk Monitoring Division and reported to the Directors every semester or twice a year. The implementation of effective and efficient risk management system is expected to increase the certainty of achieving goals of the Company. Malindo will continue to improve the methods and decision-making processes related to the risk management system.

Public Accountant Firm

KAP Tanudiredja, Wibisana, Rintis & Rekan

Gedung WTC3

Jl. Jend. Sudirman Kav. 29-31

Jakarta 12920 – Indonesia

Jakarta Selatan 12950

The Code of Conducts and Behavior serves as guideline for all parties in the Company in running ethical and integrated business activities and operations. The Code of Conducts and Behavior is dynamic in nature and constantly being updated so that it is in line with developments in regulations, norms, and business of the Company.

The Company has Guideline of Code of Conducts that applies to all members of the Board of Commissioners, Directors, employees, shareholders, and all stakeholders or business partners who conduct business transactions with the Company. The Guideline of Code of Conducts was approved on January 17, 2008, by the Boards of Commissioners and Directors. The Guideline is formulated to shape, regulate, and conform behavior so as to achieve consistent outputs in accordance with Malindo’s culture in achieving the Company’s Vision and Mission.

The Code of Conducts aims to ensure that every employee can give their best professionally, responsibly, and with integrity. All employees are expected to be able to build synergies to achieve common goals as well as have initiatives to behave and innovations in solving challenges. Code of Conducts is the guideline for employees in establishing relationships among employees, relationships with the Company, relationships with customers, and relationships with other stakeholders.

As a public company and listed on the IDX, the Company is aware on the importance of risk management in every aspect of its business. Therefore, the Company is always committed to implementing risk management in all business activities, including operational and non-operational activities. Formulation of Risk Management policies and procedures in the Company is carried out by considering the complexity of business activities, risk profile, and risk level to be taken as well as regulations stipulated by the authorities and/or financial soundness practices for the Company.

The implementation of Risk Management in the Company is focused on two things, namely capital risk management and financial risk management. The Company manages capital risk to ensure that the Company is able to continue its business continuity and also to maximize shareholder profits by optimizing debt and equity balances. Meanwhile, financial risk is managed to achieve appropriate balance between risk and rate of return and to minimize the potential effects of financial performance deterioration in the Company.

The Company manages financial risk by ensuring that sufficient financial resources are available for business operations and development, as well as to manage foreign currency risk, interests rates, credit, liquidity, and commodity prices.

The Company’s Directors periodically reviews capital risk management and financial risk management by considering the related costs and risks.

Shareholders as the capital owner have the rights and responsibilities based on the Company’s Articles of Association and Laws of Limited Companies No. 40. As the highest governance organ structure, Shareholders through GMS have the authorities to evaluate the performance of the Board of Commissioners and the Directors, request the Directors’ responsibility for all business actions that are considered incompatible with the GCG scope when managing the Company and make amendments to the Company’s Articles of Association.

General Meeting of Shareholders (GMS) is a forum for Shareholders, not given to the Board of Commissioners and Directors, with the limits specified in the Law and/or the Articles of Association. The GMS, as organ of the Company, is a forum for Shareholders to make important decisions related to capital invested in the Company, by considering the provisions of the Articles of Association and laws and regulations. Based on Law No. 40 of 2007 regarding Limited Liability Companies, the GMS consists of the Annual GMS and Extraordinary GMS that can be held at any time if required.

Public Accountant Firm

KAP Tanudiredja, Wibisana, Rintis & Rekan

Gedung WTC3

Jl. Jend. Sudirman Kav. 29-31

Jakarta 12920 – Indonesia

Share Registrar

PT Sinartama Gunita

Plaza BII Menara 1 Lantai 9

Jl. M.H. Thmrin No. 51

Jakarta 10350

Rating Agency

PT Pemeringkat Efek Indonesia (Pefindo)

Setiabudi Atrium, 8th Floor,

Suite 809-910

Jl. HR Rasuna Said Kab. 62, Kuningan

Jakarta 12920

Notary

Ati Mulyati, S.H., M.Kn.

Cyber Tower Lantai 22 E

Jl. HR Rasuna Said

Blok X-5 No.13

Jakarta Selatan 12950

Malindo has the policy of Whistleblowing System established in 2018. The purpose is to create conducive climate and encourage reporting on matters that can cause financial and non-financial losses, including matters that may damage the image of the organization.

Actions that can be deemed not in accordance with the Code of Conducts and/or violating the laws and can be reported using the Whistleblowing System mechanism are as follows:

1.Corruption, Collusion and Nepotism;

2.Cheating (Fraud);

3.Violations against applicable laws and regulations, including but not limited to the use of violations, black mailings, and harassment against employees or leaders, also the use of drugs, and other criminal acts;

4.Violations of corporate ethics as stipulated in the Code of Conducts;

5.Actions endangering the Company’s occupational health and safety, or other personnel;

6.Violations against the Company’s standard operating procedures (SOP), including but not limited to procedures of goods and services procurement and other procedures.

Malindo provides some media for reporting via:

-URL : WhistleBlowerSystem

-Whatsapp Only  : 0811145504

-Letters/Direct visit to  :  PT Malindo Feedmill Tbk, Kompleks Golden Plaza Blok G 17-22, Jl. RS Fatmawati

  No. 15, Jakarta Selatan 12420