Whistleblowing System - GOLFLINK RESORTS

Violation Reporting System

Efforts to enhance the implementation of good corporate governance principles include establishing a violation reporting system. The Company has implemented a policy related to the violation reporting system as a control system for the activities of the Board of Commissioners, Directors, and all employees. The Company encourages the participation of all individuals in the Company to provide information on violations through the violation reporting system. Information that can be reported through the violation reporting system includes:

1. Deviations from applicable laws and regulations, including tax provisions.
2. Abuse of position for interests outside the Company.
3. Corruption, Collusion, and Nepotism.
4. Fraud.
5. Gratification.
6. Violations of the Company's code of ethics or general norms of decency.
7. Actions that endanger occupational safety and health, or endanger Company security.
8. Actions that may cause financial or non-financial losses to the Company or harm the Company's interests.
9. Violations of the Company's standard operating procedures, especially related to the procurement of goods or services and the provision of benefits and remuneration.

SUBMISSION OF VIOLATION REPORTS

Reporting through the violation reporting system is facilitated through reporting channels managed by the parent company:

1. Online reports available on the internal site.
2. Email: [email protected].
3. Hard copy reports can be sent to: Violation Reporting System Management Team PT Intra GolfLink Resorts Tbk, Sentul, Desa Kadumangu, Kec. Babakan Madang, Bogor 18810 - West Java.

PROTECTION FOR WHISTLEBLOWERS

The violation reporting system team is responsible for the implementation of the whistleblower protection program, especially aspects of confidentiality and security guarantees for whistleblowers.

HANDLING OF COMPLAINTS

Reports or complaints received will be subject to an initial clarification by the Violation Reporting System Management Team, which includes the identity of the whistleblower and supporting documents. Next, an examination of the violation report will be conducted. If there is an initial indication of a violation or not, the report will be forwarded to the President Director.

Initial indications are the information provided in the report including:

1. The problem.
2. Who is involved.
3. The form and amount of the loss.
4. When and where it occurred.

Next, an initial evaluation/review is conducted based on the data held on the suspected violation report to determine or conclude whether the suspected violation report will proceed to the investigation stage or be terminated.

Additionally, the Violation Reporting System Management Team can communicate with the whistleblower if needed to:

1. Clarify and evaluate whether the material of the suspected violation reported is relevant and directly related to company-related matters (not personal matters).
2. Gather supporting evidence for analysis of the occurrence of the violation.
3. Then, discuss or hold discussions with the Investigation Team on the progress of the investigation and provide input as consideration to the Investigation Team during the investigation.
4. Draft the investigation report and provide input to the Investigation Team in preparing the final draft of the investigation report.

Next, the team submits the investigation report to the President Director, along with a follow-up plan on the investigation results.

PARTIES MANAGING COMPLAINTS

According to the Company's internal policy, the parties currently appointed to manage complaints are:

1. The Whistleblower Protection Team, which receives identified violation reports.
2. The Investigation Team, upon orders from the President Director of the Company and through an assignment letter, to conduct investigations into the complaints.

Both teams are confidential, appointed directly by the Company's Directors.