Dear Supplier,

(Company Name according to NPWP)

(Company Address according to NPWP)

Code of Procurement Ethics (COPE)

On behalf of PT Asianagro Agungjaya and its affiliated companies (each being a member of
the RGE group of companies (collectively “RGE GROUP”), I thank you for your continued
business support. All of our suppliers and contractors (hereinafter collectively called
“Suppliers”) like yourself are important and fundamental to our overall success. You
represent an important part of our supply chain.

I would like to take a moment to emphasize RGE GROUP’s Code of Procurement Ethics
(“COPE”).

The objective of COPE is to clearly communicate to you our values and principles in the
course of conducting business with you and your affiliated entities.

We seek to promote a mutually beneficial business environment which can flourish and
bring optimum value to both RGE GROUP and our Suppliers. To do this, we will conduct our
business fairly and ethically, and we expect the same from you and your affiliated entities.
Our mutual commitment and ability to promote these principles will determine the quality
and longevity of our business relationship.

Here are our values and principles:

1. Business Integrity: RGE GROUP upholds and expects honesty, integrity and fairness in
all aspects of our business transactions with our Suppliers.

The direct or indirect offer, payment, solicitation and/or acceptance of bribes in any
form are unacceptable. We aim to eliminate all forms of corrupt practices and we
further take a serious view of Suppliers and RGE GROUP employees who propagate
such behavior.

2. Fair Competition: RGE GROUP promotes fair competition in the procurement of goods
and services from our Suppliers. We aim to provide our Suppliers with the same
information so that none will have an unfair advantage over the others. We will
maintain confidentiality with regard to each of our Suppliers’ pricing and proprietary
information.

3. Open Communication: RGE GROUP encourages open communication. We seek to

receive feedback from our Suppliers to improve ourselves in line with our strategy of
constantly evolving to maximize the growth potential of RGE GROUP.

4. Conflict of Interest: Our procurement employees have signed an Employee Code of

Procurement Ethics (Employee COPE) to avoid situations whereby conflicts of interest

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 Code of Procurement Ethics (COPE)

may arise between their private financial and other activities and their employment
with RGE GROUP. Therefore all business transactions with our Suppliers will reflect
accurate and fair business dealings and not for individual benefit.

5. Gifts and Entertainment: As a matter of principle, our procurement employees are

prohibited from accepting any gifts and/or entertainment of any nature, including
accepting invitations to hospitality, business meals or similar events.

However, we understand that as a matter of business etiquette, it is not always

possible to avoid such hospitality, business meals or similar events. In the event that
RGE GROUP’s procurement employee is invited to such events, RGE GROUP shall
generally pay or contribute to the cost of such hospitality, business meals or events.
RGE GROUP will be prepared to disengage with any Suppliers who willfully disregard
this principle.

6. Compliance with International Trade Conventions and Policies: RGE GROUP expects
all Suppliers to comply with all applicable international trade conventions, rules and
policies, including those relating to economic sanctions and other trade restrictions.

By signing this COPE, you hereby represent and warrant to us that neither you nor
your subsidiaries and/or affiliated companies is engaging in or will engage in any
transactions in any country that is sanctioned by the United States, the European
Union or the United Nations or with any entity or its subsidiaries and/or affiliated
entities that is domiciled in such countries or with any entity or its subsidiaries and/or
affiliated entities that engages in transactions that violate such conventions, rules or
policies. You further confirm to indemnify us fully for any breach of such
representation and warranty.

7. Reciprocity: RGE GROUP expects all Suppliers to respect its values and principles as
listed herein. As our Supplier, you are required to communicate the foregoing to
anyone in your company who may or will deal with RGE GROUP, including without
limitation your employees, contractors, local agents, distribution network and the like.

We view any infringement of the above principles and intentions by your regional and
local sales channels as an infringement by your company and will not hesitate to take
serious action in consequence thereof, including termination of all business
relationships and de-listing from our Supplier lists. Conversely, if you detect any
infringement of the foregoing principles and intentions on our part, please inform
below contact details:

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 Code of Procurement Ethics (COPE)

Country Anti Fraud Email Anti Fraud phone

Singapore, Hong auditsgp@fpg.biz (65) 9751 2941
Kong and Canada
Malaysia auditmy@fpg.biz (60) 12 332 9187
Indonesia auditindo@fpg.biz (62) 81 2755 2528
China auditcn@fpg.biz (86) 137 3918 3310
Brazil bsc_escuta@bahiaspeccell.com (55) 71 98784 3188

8. Declaration of Existing Relationship with RGE GROUP: RGE GROUP promotes fair
competition in the procurement of goods and services from our Suppliers. To avoid
any potential, perceived or actual conflict of interest, you may be required to furnish a
declaration indicating if there is any existing relationship with RGE Group, its
executives and any employees that are relevant to the procurement process.

9. Prohibition Against Multiple Bids and Collusion: All Suppliers are prohibited from
participating in the same tender or request for proposal/quotation (howsoever
named) for the procurement of goods or services if any of the other tender
participant(s):

(i) is a subsidiary or affiliate or under common shareholding with the Supplier;

and/or
(ii) has any key staff who is/are family members of the key staff of the Supplier.

Any breach by the Supplier of this prohibition shall be considered an attempt by the
Supplier and such other tender participant(s) to collude against RGE GROUP in bad
faith. In such event, RGE GROUP shall be entitled to undertake appropriate action,
including the suspension of any and all business activities with the Supplier and the
other relevant tender participant(s), and shall further be entitled to de-list and bar the
Supplier from any future procurement activities involving RGE GROUP.

10. Compliance with Sustainability Framework. RGE GROUP is committed to

environmental sustainability in all locations and industries where we operate. Our
sustainability policies and practices are guided by our philosophy which states that
“Good business is about what’s good for the community, country, climate and
company… only then will it be sustainable.”

To honor this commitment, we require our Suppliers to comply with the RGE GROUP
Sustainability Framework and the relevant business unit’s (“BU's”) sustainability policy
in the provision of goods and services to RGE GROUP (see list below). The failure to
comply with the sustainability framework and relevant policy will be cause for a
review of the relationship and for any further action that the RGE GROUP will deem
appropriate or necessary.

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 Code of Procurement Ethics (COPE)

BU Sustainability Location
Framework or Policy
RGE RGE Forestry, Fibre, Pulp http://www.rgei.com/sustainability/sustaina
& Paper Sustainability bility-framework
Framework
APRIL APRIL Group’s http://www.aprilasia.com/en/sustainability/
Sustainable Forest sustainability-policy
Management Policy 2.0
Asia Asia Symbol http://www.asiasymbol.com/en/index.php/s
Symbol Sustainability Policy ustainability/sustainability-policy
Asia Symbol’s Wood & http://www.asiasymbol.com/en/index.php/s
Pulp Sourcing Policy ustainability/wood-sourcing-policy
Asian Asian Agri Sustainability http://www.asianagri.com/en/sustainabilitie
Agri Policy s/sustainability/sustainability-policy
Apical Apical Sustainability http://www.apicalgroup.com/sustainability
Policy
Sateri Sateri Sustainability http://www.sateri.com/en/sustainability/sus
Policy tainability-policy
Pulp Sourcing Policy http://www.sateri.com/en/sustainability/s
ustainability-policy

Kindly acknowledge and confirm your understanding of the above by signing a copy of this
COPE and returning it to us for our record.

If you have any questions relating to any of the above, please do not hesitate to let the
undersigned know.

We thank you for your valuable support and look forward to a fruitful and mutually
beneficial business relationship with your esteemed company.

For and on behalf of PT Asianagro Agungjaya

_____________________________________

Name :

Title :

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 Code of Procurement Ethics (COPE)

Supplier’s Acknowledgment of RGE Code of Procurement Ethics

Supplier’s Acknowledgement: I, (Authorized Name) as (Director/Managing Director/General

Manager), authorized signatory* of (Company Name) having the requisite power and
authority, hereby acknowledge and confirm, on behalf of the Supplier, that the Supplier

(i) understands the purpose and scope of RGE GROUP’s COPE including any applicable
declarations and sustainability frameworks;

(ii) respects and will strictly comply with the principles set out above, in order to preserve
and continue business ties with RGE GROUP; and

(iii) will ensure that the foregoing is communicated to its sales, marketing and services
networks (and the like) for compliance.

Signature Company Stamp

Name : Contact No :
Designation : Email :
Date :

*Note on authorized signatory and company stamp: The signatory on behalf of the Supplier shall be duly authorized by the Supplier to
execute the COPE on its behalf, and shall be either a key shareholder of the Supplier or of a high ranking position with executive powers
such as Managing Director, Director or General Manager.
For multinational companies, the signature of the Head of the Sales Division / Department will suffice.
Where the Supplier is a PRC entity, it is necessary for the company stamp to be affixed, for Supplier from other jurisdictions, affixing the
company stamp is optional.

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 Supplier Declaration – Deemed Connection with the RGE Group
Conflict of Interest: RGE GROUP promotes fair competition in the procurement of goods
and services from our Suppliers. To avoid any potential, perceived or actual conflict of
interest, Suppliers are required to furnish this declaration to indicate if there is any Deemed
Connection (as defined below), by filling out and signing this Supplier Declaration – Deemed
Connection.

Deemed Connection: There is a Deemed Connection if

(a) the Supplier,
(b) any affiliated companies, subsidiaries, other companies with common shareholding or
any other related parties forming part of the same group as the Supplier (collectively,
“Affiliates”),
(c) any of the Supplier’s shareholders or shareholders of any Affiliate (collectively
“Shareholder Interests”), and/or
(d) any of the Supplier’s key personnel or key personnel of any Affiliate, including but not
limited to the President, Vice-President, Chairman, Vice-Chairman, Director, Chief
Executive, General Manager, Deputy General Manager, Business Manager, Sales
Director, legal representative and other similar designations (collectively, “Key Staff”),
has any family member or relative (“Family Member”) who is a current employee within
RGE GROUP whether on a full time basis or otherwise.

Multiple Bids / Collusion: There is also a Deemed Connection if the Supplier, or any Affiliate,
Shareholder Interest or Key Staff is also participating in the same tender or request for
proposal/quotation (howsoever named) for the procurement of goods or services with the
RGE GROUP.

Family Members: For the purposes of this Supplier Declaration – Deemed Connection,
Family Member shall include (but is not limited to) any of the following relationships
(whether by birth or otherwise, save in the context of (i)):
(i) husband/wife, (ii) father/mother, (iii) son/daughter,
(iv) brother/sister, (v) uncle/aunt, (vi) grandfather/grandmother,
(vii) cousin, (viii) niece/nephew, and (ix) grandchild.

Declaration: I hereby declare, on behalf of the Supplier and all Affiliates, Shareholder
Interests and Key Staff, as follows:

(1) Deemed Connection: There is no / one or more1 Deemed Connection due to one or
more Family Members being a current/former2 employee within RGE GROUP, as
follows:
Name of Deemed Relationship with RGE BG/BU Department
Connection Supplier Worked In

1
Please delete as applicable.
2 Please delete as applicable.

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(2) Multiple Bids / Collusion: There is no Deemed Connection due to Family Member(s)
participating in the same tender or request for proposal/quotation (howsoever
named) for the procurement of goods or services with the RGE GROUP. We agree that
(i) a breach of this statement shall be deemed as an attempt by us to collude
against RGE GROUP in bad faith,
(ii) in such event, RGE GROUP is entitled to suspend any and all business activities
with us and blacklist and bar us from any future procurement activities involving
RGE GROUP.

(3) Notification: The Supplier will immediately notify RGE GROUP in writing if and when
there is a Deemed Connection that has not been previously notified to you, or if there
is any change to any of the above declarations (1) and (2).

(4) Effect of Non-Disclosure or Non-Compliance: The Supplier is aware that any material
non-disclosure or non-compliance with this Supplier Declaration – Deemed
Connection or with the Code of Procurement Ethics (COPE) may prejudice the
potential and ongoing business relationship and agreements with RGE GROUP.

Supplier’s Acknowledgment of Supplier Declaration – Deemed Connection

Supplier’s Acknowledgement: I, (Authorized Name) as (Director/Managing Director/General

Manager), authorized signatory* of (Company Name) having the requisite power and
authority, hereby

(i) acknowledge and confirm, on behalf of the Supplier and all Affiliates, Shareholder
Interests and Key Staff, that we understand the purpose and scope of this document,
and

(ii) make the above declarations (1) to (4) set out in this Supplier Declaration – Deemed
Connection.

Signature Company Stamp

Name : Contact No :
Designation : Email :
Date :

*Note on authorized signatory and company stamp: The signatory on behalf of the Supplier shall be duly authorized by the Supplier to
execute the COPE on its behalf, and shall be either a key shareholder of the Supplier or of a high ranking position with executive powers
such as Managing Director, Director or General Manager.
For multinational companies, the signature of the Head of the Sales Division / Department will suffice.
Where the Supplier is a PRC entity, it is necessary for the company stamp to be affixed, for Supplier from other jurisdictions, affixing the
company stamp is optional.

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