Good Corporate Governance


Behavior Norms and Ethics

Basic Principle of Company Code of Ethics

In efforts to improve the implementation of GCG, the Company has formulated an ethics and behavioral norm as ethical codes or a code of conduct (CoC) stated in Company’s GCG manual and will be utilized as a reference for all Company employees in interacting with shareholders and employees. The aim to formulate ethics and behavioral norms as an ethical code is to maintain and grow the Company profile, image and reputation by obligating all of the Company employees to always conduct its business activities based on a moral code which in the end will maximize the value for shareholder. Ethics and behavioral norms were formulated with the spirit of honesty, responsibility, trust, openness and partnership which will form business ethics for all Company employees and the Company itself.

The Company formulated business ethics as a method to conduct business activities which involves all aspects regarding individuals, Company, industry and also society. Harmonization upon all of these aspects will provide a foundation to the Company on how to conduct business equally per applied regulation and regardless of an individual’s or Company’s position in the society.


Corporate Culture

Ethics and behavioral norm as the Company ethical code was formulated referring to vision, mission and Company values; in which it was socialized and internalized to all of the Company’s employees to be a corporate culture. The Company sees the importance of corporate culture as a manifestation upon the Company’s big target to achieve its future vision.

“To be the leading Indonesian private infrastructure investor and developer.”

Provide infrastructure needs of the highest standard to improve quality of life and create best value for all stakeholders.

The Company Defines Corporate Culture in the Company Values as:

Growing bigger and faster by time.
Create high standard commitment.
Owns dream and confidence in approaching the future.
Always ready and enthusiastic to work more.
One team, one plan and one target.
Always together in harmony.

Ethics and Behavioral Norms

The Company firmly created ethical codes in Ethics and Behavioral Norms based on applied Company regulations and law regulations. The Company’s behavioral norms include aspects as follows:

  1. Compliance to law
    • All of the board of commissioners, directors and employees are obliged to comply and conduct law regulation and Company internal regulations.
    • Uphold and respect social norms within the society environment.
    • Record property, loans and capital owned by the Company correctly according to generally applied accounting principles.
    • Prioritize stakeholder satisfaction by providing qualified service and important assets in terms of providing excellent quality according to Company values without violating applied Company regulation and law.
  2. Actively adapt and excel toward environmental changes
    • Always actively and ready to overcome and manage business risks due changes in the infrastructure world.
    • Monitor and follow rapidly every positive changes due to environmental changes or developments.
  3. Maintain information confidentiality
    • All forms of Company information has to be kept its confidentiality according to law regulations and the nature of the business world.
    • Forbidden to purposely misuse, leak Company’s information (such as: take over information, merger or share buy back) for personal economical or other people’s interest;
    • Provide ideas to supervisor and conduct partnership with Company to prevent or to handle if it has been known that there is a possibility or it has occurred that a utilization of Company secrets has happened for other party’s purpose without the acknowledgement of the Company.
    • Business partner has the right to gain relevant information according to business relationship with the Company hence each party is able to make a decision based on equal and normal considerations.
  4. Conflict of interest
    Conflict of interest is a difference between Company economical interest with personal economical interest of Directors, Board of Commissioners, employees or main shareholders which can affect task implementation or an objective decision making.

    In conducting its task and obligation, the main shareholders, Board of Commissioners, Directors and employees are forbidden to misuse title and authority and have always to put the Company interest first.

    During decision making process, if there are any parties having conflicts of interest, the corresponding party has to inform to the other decision maker and is forbidden to participate.
    The Board of Commissioners, Directors or employees are forbidden by the Company to take business opportunities or chances for theirselves in conducting their tasks if the corresponding condition is in conflict with the Company economic interest.

    The scope of corresponding conflicts of interest includes but is not limited to:
    • If conducting work outside the Company or involved with competitor.
    • Utilizing confidential information for personal interest, the interest of others or other companies including competitors.
    • Utilizing authority to choose suppliers based on close relationship considerations (brother, in law, extended family, best friends, political party member, etc.) not a professional relationship.
  5. False statement
    False statement is a statement made (in written or oral form) which is not true or is misleading and done intentionally which may harm Company, stakeholder or other parties.

    The scope of corresponding false statement is, but not limited to:
    • Falsifying documents.
    • Giving false reports aiming to obscure or hide transactions for the interest of the Company, personal, other party or stakeholder.
  6. Protection to individual privacy
    • Protection to individual privacy is highly respected and upheld by the Company.
    • Prevent disclosure which does not comply with law, moral and ethics upon personal information.
    • The Company guarantees and pays attention to the creation of a conducive working environment, including health and work safety, in order for all employees to be able to work creatively and productively.
  7. Community environment development
    • Conduct beneficial partnership with commitment to keep all parties, including employees, stakeholders and customers and society in the vicinity.
    • Company concerns to environment is reflect towards its continuous engagement with the community to jointly conduct activities of socio-environmental responsibility by providing training to the community having mental and physical disabilities.
    • Provide scholarships to underprivileged children with high achievement and not able to continue education which its educational institution previously has been appointed to receive corresponding scholarship.
  8. Relationship with Government employee and executive
    • Relation between employee within a Company and the Company relationship with government officials and regulators are always well managed by the Company based on normal, reasonable and ethical conduct.
    • In keeping a good relation in between employees, the Company must ensure the availability of information which needs to be known by the employee through a good and punctual communications system.
    • In keeping a good relation with the government, the Company acts proactively but in normal relationship boundaries, reasonable and with ethics in expanding business which is translated into finding an exact asset, approved originality and develop good relationship with the government based on Company value of Proactive.
    • In the relationship between Company employees and the government executive, the Company forbids gifts having a beyond the limits value which may cause a perception by other parties as something that would influence the recipient’s decision.
  9. Gift
    • Gift or grant is given in forms of cash, goods, service and others done without a return compensation as conducted in trading, even it is possible that the grantor hopes a return or in forms of prestige or power.
    • Company forbids receiving gifts in any form related to Company business activities. Except if the gift is within normal limits and not causing others the perception as something that would influence the recipient’s decision.
    • The Company forbids giving gifts in any forms. Except if the gifts are given in business promotion activities and has values within normal limits and not causing others perception as something that would influence the recipient’s decision.
  10. Donation
    Granting donation in forms of money or Company asset for charity is allowed by the Company as long as it is within the law regulations and within normal limits, of decency as the Company has set.

    Giving donation in forms of cash or Company asset to a political party, one or more individuals, candidates of the legislative or executive member is allowed by the Company as long as the value of the donation, terms and conditions of giving the donations complies and has no conflict with applied laws and regulations.
  11. Involvement in political activities
    The Company lets the members of the Board of Commissioners, Directors and employees to participate in political activities or to be a member of a political party. But the Company forbids members of the Board of commissioners, Directors or employees to conduct political activities within the Company vicinity for any reasons, including forcing other to choose or participate in one political party.

    The Company forbids the utilization of assets or facilities given by the Company for political activities such as: utilization of Company car or building for political campaign, extension services to Company employees within the Company vicinity for political campaign activities.

Socialization and Internalization


The Company firmly created ethical codes in Ethics and Behavioral Norms based on applied Company regulations and law regulations. The Company’s behavioral norms include aspects as follows:

To increase self-potential for all its employees is important for the progress of a Company, PT Nusantara Infrastructure through its Human Resources (HR) Division held a “Sharpen the Saw” Program to improve their employee’s skill and knowledge.

This program is also called “Nusantara Campus” because apart from being targeted to all its employees, this activity also has a curriculum package in several majors, categories and thematic. These categories include general skills, special skills, general knowledge, general competencies and special competencies.

This activity is held in the form of sharing session, which has been carried out virtually since June 2021. Various teaching methods has been carried out as a package to be interesting and interactive way between the presenters and participants. Friday is used as a “sharing session day” or a day that is considered appropriate for all employees to be able to learn together, as well as to recharge employees' minds and energy after a week of work.