Corruption Prevention

The Board of Commissioners, Board of Directors and all TOTAL people uphold fair competition, sportivity, professionalism and good corporate governance principles. In addition, TOTAL is committed to creating a healthy business climate; avoiding actions, attitude and activities potentially leading to conflict of interest, corruption, collusion and nepotism (KKN); and prioritizing the Company’s interests over personal, family, and group interests. The Company also takes into account the following policies on anti-corruption:

• Law No. 8 of 2010 concerning the Prevention and Eradication of Money Laundering, and;
• Law No. 20 of 2001 on the Amendment to Law Number 31 of 1999 concerning the Eradication of the Criminal Act of Corruption.

Therefore, TOTAL has established a set of guidelines on ethical conduct which includes business ethics. The guidelines comprise the Company’s code of conduct that clearly and briefly outlines, in detailed direction, on how to comply with business ethics.

In addition to the internalization of ethical guidelines, the Company also implements a whistleblowing system that encourages TOTAL employees (TOTAL/"M-TOTAL Humans”) and external parties to not hesitate to report corruption or actions that have the potential or lead to corruption. The protection of the whistleblower's identity by the Company becomes a part of effective reporting mechanism.

Anti-Bribery Management System

The implementation of the ISO 37001:2016 Anti-Bribery Management System (SMAP) at the Company is a manifestation of the Company’s commitment to instilling a culture of anti-bribery and other acts of corruption. SMAP assists the Company in controlling bribery practices through various measures including the issuance of the anti-bribery policy, appointment of Anti-Bribery Compliance Function (FKAP) with the authority to manage and implement an Anti-Bribery Management System (SMAP). Socialization and implementation related to the Anti-Bribery Management System, Whistleblowing System and Gratification Control as well as Good Corporate Governance in the Holding and Subsidiaries.

Assessment Related to Corruption Risk

TOTAL has established an Internal Audit Unit to carry out the evaluation process and effectiveness, efficiency and compliance in implementing the internal control system. Internal Audit Unit personnel have professional qualifications and competencies which are characterized by professional certification of internal auditors in the field of Internal Audit and Risk Management.

The Internal Audit Unit performs their duties based on an Internal Audit Charter, an official document that sets out roles and responsibilities, authorities and work relationships with all related parties. The charter was ratified by the President Director by approval from the President Commissioner on January 8, 2018. This charter has become a guideline to carry out all internal audit activities to enable an effective internal control system.

As part of the Company's strategy in increasing the efficiency and effectiveness of internal supervision, the Internal Audit Unit always upholds independence and objectivity. In monitoring criminal acts and corruption risks, the Internal Audit Unit must be able to plan, implement and report audit tasks independently and independently without being influenced by any interests in accordance with the considerations of applicable professionalism and audit standards and relying on existing evidence and facts. During this reporting period, there was no corruption in the Company.

Anti-Corruption Communication and Training

TOTAL is committed to creating clean business practices and avoiding all forms of fraud. One strategic step in preventing corruption is to develop and use a whistleblowing system effectively. The existence of a violation reporting system allows internal and external parties to report incidents related to violations of corruption, fraud, or corporate ethics irregularities. TOTAL has a policy to protect the identity of whistleblowers who report actions or the potential for corruption and management of the results of a whistleblowing system that is carried out professionally and independently.

In addition, TOTAL also routinely disseminates and disseminates information about the code of conduct. These activities include the internal communication carried out by the HC Department to all TOTAL People. TOTAL's strong commitment in internalizing the code of conduct to all employees is realized through a policy that requires all employees to participate in the code of conduct training. The traning has the following objectives, purpose and benefits:

Providing understanding for each TOTAL people that all the Company’s activities are grounded on good corporate governance principles;

• Encouraging all TOTAL people to perform well in carrying out the Company’s activities;
• Creating a healthy and convenient work atmosphere in the Company’s environment;
• Minimizing potential deviation that can influence the Company’s image.
• Generating common commitment to realizing the Company’s vision and mission professionally by upholding business ethics;
• Acting as a guideline of conduct for all TOTAL people that must be complied in implementing all the Company’s activities;
• Avoiding conflict of interest in implementing all the Company’s activities;
• Realizing harmonious relationship with the Stakeholders.