PROVISIONS REGARDING THE OCCURRING OF PERSONAL CONFLICT (INSIDER TRADING)

In accordance with Decree No.39.3/SK/WBP/PEN/2017 concerning Corporate Governance Guidelines (Good Corporate Governance)

• A conflict of interest is a difference in interest between the Company's economic interests and the personal economic interests of members of the Board of Directors, Members of the Board of Commissioners, or Shareholders.
• PT Waskita Beton Precast Tbk has developed a conflict of interest policy that ensures that all Board of Commissioners, Directors and employees prevent themselves from carrying out transactions that contain a conflict of interest without prior approval from the Shareholders.
• Members of the Board of Commissioners and Directors must disclose share ownership in other companies in a special list as required by applicable laws and regulations.
• PT Waskita Beton Precast Tbk will remind all its employees, at all levels, to be aware of the conflict of interest policy. Every employee must report and fully disclose any activities that have the potential to contain a conflict of interest.
• All transactions containing conflicts of interest that occur between the Company and its employees, members of the Board of Directors and the Board of Commissioners must be fully disclosed to Shareholders.

A conflict of interest occurs if:

1. Abusing one's position for personal, family or other parties' interests or profits.
2. Utilizing confidential information and Company business data for purposes outside the Company.
3. Holding positions in competing companies and/or business partners or prospective business partners of the Company that have the potential to create a conflict of interest.
4. Having a blood and/or marriage relationship up to the third degree with a member of the Board of Directors and/or a member of the Board of Commissioners.
5. In the case of discussions and decision making that contain elements of conflict of interest, the parties concerned are not permitted to participate.
6. Own a business that is directly related to the Company's activities.

In the operational sector, especially in the procurement of goods and services, there "should not be" any conflict of interest, namely:

1. Conflict of interest in the procurement of goods and services.
2. There are providers of goods and services that are affiliated with employees and/or Directors of PT Waskita Beton Precast Tbk.
3. The procurement of goods and services is controlled by a group of certain providers of goods and services.

The application of conflicts of interest within PT Waskita Beton Precast Tbk is strongly influenced by:

1. Leadership commitment, among the Board of Commissioners, Directors, Management and employee work groups.
2. Driving the implementation of conflicts of interest and their development by the HR & General Department.
3. Socialization to every level of employee.

Sanctions for conflict of interest violations

1. Every employee who commits a conflict of interest violation will be given sanctions according to the severity, nature and frequency of the violation.
2. The procedures for imposing sanctions are in accordance with those contained in the PT Waskita Beton Precast Tbk Company Regulations.

Requirement to report conflict of interest violations

1. Every employee is required to report conflict of interest violations to the Human Capital Management Division.
2. Every employee who reports a suspected conflict of interest violation must clearly disclose his or her identity.
3. The confidentiality of the identity of the reporter must be maintained, except when necessary to follow up the report in accordance with Company policy.
4. There is no penalty imposed on the reporter if the violation actually occurs, unless the person concerned is also involved in the violation and/or the report is incorrect.
5. The Human Capital Management Division must follow up on the report within the limits of its authority.
6. The Human Capital Management Division must report to the Board of Directors for action to be taken in accordance with Company policy.